CLP environmental hazard tests

Environmental tests are the same for both substances and mixtures.  All environmental hazard tests (and more which are not included under CLP) are covered by REACH, see 440-2008 Test Method Regulation – 04-03-2016 , and/or by the OECD animal tests, see http://www.oecd-ilibrary.org/environment/oecd-guidelines-for-the-testing-of-chemicals_chem_guide_pkg-en .

You should only need to carry out environmental hazard tests on substances which are not registered for REACH, or where you are required to derive the CLP classification yourself (e.g. for a novel substance made or imported at less than 1 tonne per annum, or where you are the only REACH registrant).

You should only carry out environmental hazard tests on animals for mixtures where the algorithm method of classification is believed to give an incorrect answer, (e.g. due to suspected synergistic effects where components interact to give a greater hazard than the algorithm method predicts), and all other classification routes (QSAR, read-across) have been ruled out.

Environmental hazard test methods

A list of acceptable test methods is given in CLP for each environmental hazard, and is summarised here for reference: Summary of environmental hazard tests for CLP and Transport v1.0 09-05-2017 . This document also includes appropriate REACH methods and OECD test guidelines, where they exist.

Who can carry out CLP environmental hazard tests

Environmental hazard tests must be carried out by a fully certified test house which is accredited to GLP and subscribes to any local laws on animal testing.  Fish are vertebrate animals, and as such need to be treated with high welfare standards, and tests on them should be avoided if possible.

There is no requirement for the laboratory to be based in the EU, although this guarantees that animal welfare is of a very high standard, and that only animal tests approved within the EU are used.  Using a non-EU lab (especially in India or China) may mean that a non-EU approved animal test might be used accidentally.